Eaton Pushes Rethink On Tax Court Pricing Win

Law360, Washington (November 29, 2017, 1:42 PM EST) -- Eaton Corp. is urging a U.S. Tax Court judge to reconsider her decision refusing to reopen a victory for the company over advance pricing agreements canceled by the Internal Revenue Service, with Eaton arguing the tax agency is “incorrect” when asserting the parties have resolved a purportedly outstanding issue.

Tax Court Judge Kathleen Kerrigan should reconsider her brief Nov. 9 decision holding as “resolved” questions over the right arm’s-length royalty rate for 2006, Eaton said, as it tries to further entrench its July win holding that...
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